Pembrokeshire Coast National Park

Local Development Plan 2

Place Plan Toolkit

Developing Affordable Housing with a Land Trust

Consultation: September 2020

Adoption: May 2021

This item is also available in Welsh/ Mae’r eitem hon ar gael yn Gymraeg hefyd

Pembrokeshire Coast National Park Authority

What is the purpose of this Guidance? ...... 2 What is Affordable Housing? ...... 2 Finding a suitable building site ...... 2 Bringing A Site Forward: Tips and Advice ...... 3 Land owner Intention...... 3 Landscape Impact ...... 3 Amenity ...... 3 Ecological Sensitivity ...... 3 Flood Risk ...... 3 Sewerage Capacity Water Supply ...... 3 Access for people and traffic ...... 3 Historic Environment ...... 3 Affordable Housing Need ...... 3 Further Advice and Support ...... 4 Appendix 1 Extract of the Adopted Pembrokeshire Coast National Park Local Development Plan 2 (September 2020) ...... 6 Appendix 2 Centres listed in Local Development Plan 2 ...... 8 Appendix 3 Suitable Sites for Affordable Housing ...... 9 Appendix 4 Site Assessment ...... 13 Appendix 5 Useful Contacts ...... 19 References ...... 1

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What is the purpose of this Guidance?

1. The purpose of this Guidance is to assist in bringing forward affordable housing developments with the help of Community Land Trusts. This is one of a series of Place Plan Toolkits that the National Park Authority intends to prepare.

2. A Community Land Trust is set up by the community for the community. The Community Land Trust endeavours to keep the homes or assets permanently affordable. This means that the home or asset is not just made affordable for the first buyers but that the Community Land Trust maintains the affordability of the housing or asset in perpetuity.

3. Pembrokeshire benefits from having its own funded Community Land Trust Officer who is coordinating community initiatives for bringing forward affordable housing.

What is Affordable Housing?

4. For the purposes of the land use planning system, affordable housing is defined as housing that is available exclusively to people in housing need that cannot afford to access the open market.

Finding a suitable building site

5. A Community Land Trust may find that land will come forward from local landowners who are swayed by the emphasis that Community Land Trusts place upon meeting local needs and the assurance the land and homes will be stewarded in perpetuity for the benefit of the local community.

6. There are three potential sources of sites for Community Land Trust:

. allocated sites (shown in the Local Development Plan as being suitable for housing development with a proportion of the site safeguarded for affordable housing delivery) . windfall sites (unforeseen sites) and; . Affordable Housing Exception Sites (sites currently lying outside the Centre). See Policy 49 of Local Development Plan 2 in Appendix 1. The Centres listed in Local Development Plan 2 can be found in Appendix 2.

7. When looking for a suitable site for a Community Land Trust development the Trust may wish to consider the Candidate Site Register used when developing Local Development Plan 2.

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8. For ease of reference a summary for suitable exception sites for affordable housing from that exercise is attached at Appendix 3 Suitable Sites for Affordable Housing along with a link to the Register.

9. If a new site is proposed by the Community Land Trust (i.e. one that has not previously been identified), the National Park Authority will undertake an assessment of the site’s suitability for development free of charge.

10. This assessment will consider the initial suitability of the site in terms of whether it lies within or adjoining (if proposed solely for affordable housing) a Local Development Plan 2 Centre and the size and scale of the site is in keeping with the character of the Centre. – a list of Centres and the Communities they lie in is provided in Appendix 2 Centres listed in Local Development Plan 2. A copy of the full assessment form is provided in Appendix 4 Site Assessment.

11. The Authority will use the same approach it used to provide the assessment of sites for Local Development Plan 2. The parameters below will help inform a site’s suitability in more detail.

Bringing A Site Forward: Tips and Advice Land owner Landscape Impact Amenity Intention Privacy, Light, Noise Would development of the Are they willing to site conserve or enhance release the land? the character of the village / street scene / surrounding context? Mitigation? Ecological Flood Risk Sewerage Capacity Sensitivity Water Supply Will the development be Is the site or species vulnerable to, or increase Can the sewerage system protected or worthy of the risk of flooding? cope? Can water be protection? supplied? Access for people Historic Environment Affordable Housing and traffic Need Impact upon any of the Can the road network following present on the site The proposal meets cope with the amount or neighbouring: Listed affordable housing need in and type of traffic? Buildings, Conservation the locality. Motorist and pedestrian Areas, Scheduled safety. Monuments.

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12. The National Park Authority welcomes the opportunity to provide early advice on the suitability of a site’s development.

13. The section below provides further advice on the support the National Park Authority can give with the application of Policy 49 of the Local Development Plan 2, set out in Appendix 1 Extract of the Adopted Pembrokeshire Coast National Park Local Development Plan 2 (September 2020) for ease of reference.

Further Advice and Support

14. The National Park Authority is generally supportive of Community Land Trust developments.

15. The Authority will start with the presumption that all community-led developments will be supported, unless there are fundamental problems with a proposal (for example, it would cause unacceptable highway safety problems). The Authority will work with the Community Land Trust to find ways to make its proposal acceptable if we find there are problems which we think can be resolved.

16. To help the Community Land Trust, any proposed development should be discussed with the Authority at an early stage to prevent any unnecessary work. The Authority will provide free initial pre-application advice to community-led initiatives and encourages community groups to refer schemes to the Design Commission for at an early stage.

17. For sites adjoining Centres, the impact on the character of the locality and the countryside will be important to consider. Schemes should avoid causing significant harm to the appearance and character of the local landscape and townscape, or harm to heritage assets (including their setting). This will partly be facilitated by considering site location – but also by considering issues of overall scale, design and layout.

18. Where there is potential for some harm, the National Park Authority will work with the Community Land Trust to overcome this, or put in place a mitigation scheme. In reaching a decision on a proposal, the National Park Authority will balance any remaining harm a scheme might have with the benefits of the proposal.

19. Considerable positive weight will be given to proposals whereby it is clear the proposal is genuinely community-led and genuinely has community support. A Community Land Trust is established for the express purpose of furthering the social, economic and environmental interests of a designated local community by managing land and other assets. The assets are protected for the long term by a legal asset lock, any profits made must be only used to further the objectives of the Community Land Trust, and there must be opportunities for local people to become members and for the members to

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control the Community Land Trust. For these reasons, the Authority considers that a Community Land Trust is well placed to bring forward a community-led development proposal, particularly if the community itself will take ownership of valuable community assets as a result.

20. Retained in perpetuity: it will need to be demonstrated that any benefits provided by the scheme can be retained by the Community Land Trust in perpetuity. All schemes therefore need to demonstrate that they will be financially viable. The Community Land Trust will have to clearly define the community that is to benefit from the development and require that the assets are retained in perpetuity for the benefit of the community. This community (which will be in need of affordable housing locally) will need to be clearly defined in consultation with Pembrokeshire County Council as housing authority. The Community Land Trust will need to be able to show how it will secure the benefits for this community in perpetuity. This is normally recognised in planning through the use of a S106 Agreement1.

21. For useful contacts see Appendix 5 Useful Contacts.

1 Planning obligations under Section 106 of the Town and Country Planning Act 1990 (as amended), commonly known as s106 agreements, are a mechanism which make a development proposal acceptable in planning terms, that would not otherwise be acceptable. They are focused on site specific mitigation of the impact of development.

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Appendix 1 Extract of the Adopted Pembrokeshire Coast National Park Local Development Plan 2 (September 2020) Policy 49 Affordable Housing Exception Sites

Affordable housing sites within or adjoining the Plan’s Centres will be permitted where it can be demonstrated that:

a) The site is solely for affordable housing and there are clear and adequate mechanisms to ensure that the benefits of affordable housing will be secured for initial and subsequent occupiers; and b) A genuine need for affordable housing has been identified; and c) The site is of a size and scale that is commensurate with the defined need and is in keeping with the form and character of the Centre.

Reasoned Justification

This policy will allow the development of sites for 100% affordable housing to meet local needs in locations not normally acceptable for residential development in accordance with National Planning Policy and TAN 2.

The policy aims to help sustain rural communities and retain people in their local communities by allowing the development of small scale affordable homes to meet local identified housing need. Promoters of such sites include Registered Social Landlords, the County Council and Community Land Trusts.

New affordable homes should be of a size, scale and tenure that is commensurate with the defined need. Evidence of need can be drawn from the Local Housing Market Assessment, the Common Housing Register and Community Council surveys.

With regard to criterion c) the policy aims to sustain rural communities and retain people in their local communities by the development of small scale affordable homes developments to meet a locally identified need. The Centres of the National Park vary in size, in particular the Rural Centres, and therefore care needs to be taken to ensure that the development is in keeping with the form and character of the Centre and also that as the number of affordable units increase it can create difficulties around maintaining a community of mixed tenures.

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The affordable housing will need to remain available in perpetuity to meet affordable housing need through the use of obligations or conditions. Affordable housing exception sites are not appropriate for market housing.

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Appendix 2 Centres listed in Local Development Plan 2

Service and Tourism Centre Local Centres Newport St Davids Rural Centres lying in the National Park Angle Manorbier Station Bosherston Broad Haven Moylegrove Castlemartin Mynachlogddu Cresswell Quay Dale Newgale Nolton Haven Felindre Farchog Pontfaen Jameston Rosebush Lawrenny Little Haven St Ishmaels Lydstep Trefin Rural Centres lying partly in the National Park Carew*2 Milton* * New Hedges Hook* Pleasant Valley* Houghton* Roch* * Square and Compass Llangwm* Wiseman’s Bridge

2 *Lies predominantly within the County Council’s planning jurisdiction.

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Appendix 3 Suitable Sites for Affordable Housing

Site Name / Location Number3 / Thumbnail Picture Summary Summary Angle Site 116A Highway Authority constraint East of West Bay to more than 5 houses at Close, Angle this site. Pumping station capacity limited to a maximum of 10 more houses in Angle without upgrading. Angle Site 118A Highway Authority constraint North of West Bay to more than 5 houses at Close this site. Pumping station capacity limited to a maximum of 10 more houses in Angle without upgrading. Dale Site 087 Identified for housing in Land at Castle Local Development Plan 1 Way, Dale for up to 12 houses.

Dale Site 123 Site for up to 5 houses. South of Castle Sensitive design required to Way, Dale protect the landscape.

Dinas Cross Site 008 Small garden site suitable Bryn y Wawr, for 1 or 2 houses within the Dinas Cross Centre boundary for Dinas Cross.

Dinas Cross Site Site for up to 5 houses. 013A/054/074A/ Access to this site needed 095A/135A from A487, requiring Springhill, Dinas demolition of existing Cross building.

3 for more detail see Site Register: https://www.pembrokeshirecoast.wales/planning/planning-policy/local- development-plan-2/local-development-plan-replacement-stages/submission/consultation-report/

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Site Name / Location Number3 / Thumbnail Picture Summary Summary Dinas Cross Site 136A Small area of this site would Land south of be suitable for 5 to 7 A487, south-west houses. Design and layout of Castle Terrace, would need to be sensitive Dinas Cross to the green wedge designation in this location. Herbrandston Site 149 Land identified for up to 12 East of houses in Local Herbrandston Hall, Development Plan 1. Herbrandston

Llanrhian Site 014A Land identified for up to 15 North of Heol houses in Local Crwys, Trefin Development Plan 1.

Maenclochog Site 128 Small site for 1 or 2 houses. South of the Caravan Park, Rosebush

Maenclochog Site 129 Site suitable for up to 10 West of Rosebush houses. Feasibility study required to establish available capacity at waste water treatment works.

Manorbier Site 126 Site for up to 4 houses. South of The Topography may increase Green, Lydstep development costs. Access improvements required and a cordon sanitaire required to protect against air pollution arising from the waste water treatment works. Marloes Site 053 Small site for 1 or 2 houses Land formerly within Centre boundary for occupied by South Marloes. Bungalow, Marloes

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Site Name / Location Number3 / Thumbnail Picture Summary Summary Nevern Site 115 Small site within Centre Land at the rear of boundary of Felindre the Salutation Inn, Farchog. Objections from Felindre Farchog Trunk Road Agency would need resolution to achieve access to the site from the A487. Newport Site 083 Site identified for Land adjacent to employment use in Local Newport Business Development Plan 1 which Park, Newport has not transpired. Suitable for 5 to 7 houses. Additional houses may require upgrading of waste water treatment works. Solva Site 102 Identified for up to 12 Bank House, houses in Local Solva Development Plan 1. Legal covenant may restrict or constrain development. Waste water treatment works awaiting upgrade by Dŵr Cymru / Welsh Water

prior to any further development in Solva. Solva Site 111 Identified for up to 18 Land adjacent to houses and sports facilities Bro Dawel, Solva in Local Development Plan 1. Waste water treatment works awaiting upgrade by Dŵr Cymru / Welsh Water prior to any further

development in Solva. Solva Site 151 Large site adjoining the Land north of Centre boundary for Solva. Maes Ewan, Solva Development of some of this land for affordable housing would be acceptable. Waste water treatment works awaiting upgrade by Dŵr Cymru / Welsh Water prior to any further development in Solva.

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Site Name / Location Number3 / Thumbnail Picture Summary Summary St Ishmaels Site 058 A small site which is the Land to the rear of garden of an existing Cross Cottage, St property within the Centre Ishmaels boundary of St Ishmaels suitable for a single house.

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Appendix 4 Site Assessment

Site Location Community Site Number Submitted by Proposed Use

Section 1 – Key Questions

Criterion Commentary Assessment Criteria A Is the site compatible with Yes the National Park Yes with mitigation Purposes and Duty? No B Is there evidence to No question the viability or Possibly deliverability of the site? Yes C Does the site have a Yes – supports this planning history? proposal No history Yes – conflicts with this proposal D Is the site compatible with Yes the Preferred Strategy of No Local Development Plan 2?

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Section 2 – Detailed Site Appraisal

Criterion Commentary Assessment Criteria 1 Is the site within or Within a Centre adjoining an existing Adjoining edge of Centre? Centre Countryside 2 Is the site located on Brownfield previously developed (brownfield) land, as Part Brownfield/part defined by Planning Greenfield Policy Wales (page 37, Greenfield Edition 11) 3 Would the development of No loss the site result in the loss of the best and most Grade 3a and above versatile agricultural land? Grade 1 or 2 4 Is the site accessible from Yes a public highway? Yes – with improvements No 5 Is the nearby highway Yes network capable of accommodating the Yes – with resulting traffic improvements movements? No 6 Is public transport Yes – more than 5 available? buses / trains per day Yes – fewer than 5 buses / trains per day No 7 Would the development of Would not result in a the site result in the loss loss of publicly accessible Would affect public open space? access but could be mitigated Would result in a loss 8 Is the site within 100m of existing water, sewerage, Yes electrical, gas and telecommunications No systems? 9 Is there a possible No infrastructure capacity

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Criterion Commentary Assessment Criteria issue that could act as a Yes – but can be constraint to addressed through development? investigation/mitigation Yes 10 If the site is proposed for Close to ‘good residential development, neighbour’ employment how does it relate to any uses employment uses Not close to adjacent to the site? employment uses Close to ‘bad neighbour’ employment uses 11 If the site is proposed for ‘bad neighbour’ Yes development – i.e. employment are there any residential properties No within 400m of the site? 12 Does the site include or is No it close to any areas designated for biodiversity Adjacent / close importance at an Within international level? 13 Does the site include or is No it close to any areas designated for biodiversity importance at a national Adjacent / close level? Within 14 Does the site include or is No it close to any areas designated for biodiversity importance at a local Adjacent / close level? Within

15 Is the site within or No adjacent to a Regionally Important Geodiversity Adjacent / close Site? Yes

16 What is the outcome of Positive the biodiversity assessment (if Neutral applicable)? Negative

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Criterion Commentary Assessment Criteria 17 Is there a threat to mature No trees or hedgerows within or adjacent to the site? Adjoining

Within 18 Is the development of the No site likely to affect the habitat, breeding site or resting place of a Potentially protected species? Yes 19 Is the site located within No or close to a designated open space? Adjacent / close

Within 20 Is the site located within No or close to an area designated for cultural heritage importance? Adjacent / close

Within 21 Is the site within or No adjacent to a Conservation Area? Adjacent / close

Within 22 Are there any Listed No Buildings within or adjacent to the site? Adjacent / close

Within 23 Are there any Scheduled No Monuments within or adjacent to the site? Adjacent / close

Within 24 Is the site located within No or adjacent to an area prone to flood risk? Adjacent / close

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Criterion Commentary Assessment Criteria

Within 25 If the site is within or Yes adjacent to an area prone to flooding is the risk Yes, with mitigation acceptable, having measures regards to vulnerability of the development No proposed. 26 Do the topographical No characteristics of the site present an obstacle to Yes but can be development? mitigated Yes significant enough to prevent development 27 Would development of the No site have a detrimental impact on the character of Yes but can be the Centre or locality? mitigated Yes significant enough to prevent development 28 Is there evidence that the No site could consist of potentially contaminated Yes, but capable of land? remediation Yes and unlikely to be capable of remediation 29 Is the site within a No minerals safeguarding zone? Yes but can be mitigated Yes 30 Is the land likely to be No adversely affected by stability issues? Yes but capable of mitigation Yes

Overall Assessment (include commentary on suitability under Policy 49 - Affordable Housing Exceptions Sites):

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Recommendation

Compliant in principle with Local Development Plan 2 Yes Further No Information Required

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Appendix 5 Useful Contacts

For Pre Application Advice on development proposals and obligations required

Pembrokeshire Coast National Park Authority Development Management Llanion Park Pembrokeshire SA72 6DY

Telephone: 01646 624800 Email: [email protected]

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References

National Assembly for Wales: Members’ Research Service: Quick Guide Community Land Trusts June 2010 https://senedd.wales/Research%20Documents/Community%20Land%20Trusts%20- %20Quick%20guide-28062010-188743/qg10-0014-English.pdf

Examples of Community Land Trusts

https://chagfordcommunitytrust.org.uk/ http://www.communitylandtrusts.org.uk/what-is-a-clt/success-stories/rural-clts/christow-clt https://www.peakdistrict.gov.uk/learning-about/news/archive/2013/news/community-land-trust- wins-first-approval-for-affordable-homes-in-the-peak-district

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